Digital Product Passports (DPPs) are designed to collect and share data about a product and its supply chain across the entire value chain. DPPs enable all stakeholders, including consumers, to gain a deeper understanding of the materials used in products and their associated environmental impacts.

Digital product passports are a mandatory component of the Ecodesign for Sustainable Products Regulation (ESPR) and one of the key actions under the Circular Economy Action Plan (CEAP). Under the ESPR, all regulated products — including textiles, construction materials, industrial and electric vehicle batteries, and at least one additional key value chain identified in the Circular Economy Action Plan, such as consumer electronics, packaging, or food — will be required to implement DPPs.

The implementation of digital product passports in these value chains is designed to support:

• Sustainable product production: Utilising the r-strategies to enable a circular economy, boosting material and energy efficiency, extending product lifetimes, and optimising product use.
• Businesses to create more value through circular business models: With improved access to data with digital product passports, more businesses can implement service and repair-based business models.
• Consumers to make more informed purchasing decisions: By providing them with accurate information on the true impact of their buying behaviours.
• Compliance with legal obligations: DPPs will also act as a record of the standards a product complies with and provide auditors with information to evaluate and verify.

In this article, we will discuss what is known about digital product passports, such as who needs to comply, what data needs to be included in a DPP, how to implement a DPP system, and why it is important.

Who needs to implement digital product passports?

While battery passports have set a precedent for digital product passports, the Ecodesign for Sustainable Products Regulation has outlined specific requirements for various sectors. These requirements focus on targeted product categories that align with the EU Circular Economy Action Plan. According to the EU ESPR, the first batch of products that need to have DPPs include:

• Iron and steel
• Aluminum
• Textiles (garments and footwear particularly)
• Furniture 
• Tyres
• Detergents
• Paints
• Lubricants
• Chemicals
• Energy-related products with ecodesign requirements
• Information and communication technology products & other electronics

Manufacturers, importers, distributors, and retailers of these products must make their DPPs accessible by 19 April 2025. More categories will be known in the upcoming years, as the Commission is set to regularly update the list of products having to comply with the Regulation.

The textiles, construction, electronic waste, plastics, chemicals, and automotive sectors are all experiencing significant pressure and initiatives to adopt more sustainable business practices. Legislation is being developed to create connections across these various product categories, reflecting the growing emphasis on digitisation, interconnected data sets, and the assessment of environmental impacts throughout product life cycles.

Digital product passports are also not a stand-alone idea; they are part of a broader framework that includes elements of traceability, chain of custody, supply chain collaboration, and data-sharing requirements, all of which are integral to a range of other regulations. These all form part of the European Union’s Digital Transition and Data Spaces plans designed to harmonise and standardise access to data. Some of the relevant regulations include:

What information needs to be included in a digital product passport?

While data requirements for digital product passports have been defined by the ESPR, implementation calls for the whole supply chain to cooperate and define the crucial information that could prevent a product from going to waste. Data requirements for the specific products or product groups might vary and more information will be published in the Supplementing Acts to the ESPR. Here are the data requirements for digital product passports:

• Unique Product Identifier

Each DPP links to a unique product ID via a data carrier (e.g., barcode, QR code) placed on the product, its packaging, or in accompanying documentation.

• Compliance with Global Standards

The DPP follows ISO/IEC 15459:2015 standards to ensure consistency, quality, and global interoperability.

• Structured, Machine-Readable Data

All information in the DPP is structured, machine-readable, and based on open standards, making it searchable and compatible with digital systems.

• Comprehensive Product Information
• The DPP contains key details about the product model, batch, or individual item, enhancing transparency across the supply chain.
• Controlled Access to Information
• Access to DPP information is regulated per Article 10, with specific access levels for each product group as set by Article 4.

For a complete list of the requirements for digital product passports laid out in the Ecodesign for Sustainable Products Regulation (ESPR), follow our step-by-step guide on how to comply with ESPR for manufacturers, importers, distributors and retailers.

Battery passport criteria

From 2026, every industrial and electric vehicle battery must come with a digital product passport. The required information links to safety requirements and the targets for recycled content in batteries. More specifically, data must be provided for:

• Material sourcing
• Carbon footprint
• Percentages of recycled materials used 
• Battery durability 
• Repurposing and recycling guidelines

Digital product passports for other types of products

The 2024 Ecodesign for Sustainable Products Regulation provides a framework for producing more sustainable products in the EU and states that DPPs will play a role in ensuring this. The EU Strategy for Sustainable and Circular Textiles and the Construction Products Regulation have also outlined digital product passports as potential future requirements to ensure compliance with their proposed frameworks. More specific guidelines on these sector-specific digital product passports are expected by the end of 2022.

The criteria for each type of DPP will then be determined by the specific materials, processes, and data protection requirements relating to each product. However, if DPP systems develop with significantly different requirements across various sectors, this could present a significant challenge for raw material suppliers catering to a diverse range of industries. 

How to implement a digital product passport system?

Implementing a new enterprise system to comply with digital product passports (DPPs) is a significant undertaking. Concerns have already been expressed that DPPs will become a bureaucratic system placing additional regulatory burdens on businesses, particularly small to medium enterprises (SMEs). DPP systems must be user-friendly and cost-effective, able to safeguard proprietary information while ensuring accessibility for all businesses.

The practicalities of DPP implementation

From an operational perspective, it is not as difficult as it may first seem. Once a framework is defined for the information to be included in digital product passports, traceability software can be used to standardise data sets coming from existing ERP systems. The required unique product identifiers can use existing technologies such as barcodes, QR codes, RFID tags, or similar, for digital product passport data submission. In the end, this process can be almost entirely automated. 

Implementing a data transfer infrastructure for DPPs

In most cases, the main gap for companies lies in establishing the infrastructure for an open, standard, interoperable format for the digital product passport data – one that is also machine-readable, structured, and searchable, as outlined in the essential requirements of Article 9 of the Proposal for Ecodesign for Sustainable Products Regulation. 

But thanks to the rapidly evolving world of blockchain, decentralised systems will be able to meet these requirements and provide key product information to the parties who value it most. These technological advances also mitigate the past criticism that decentralised blockchains have high operating costs and energy consumption. New blockchain technology developments will allow vast amounts of secure data transfer, using a fraction of the energy.

Data storage for DPPs: Protecting proprietary information

Ensuring data security is essential for the protection of trade secrets when creating digital product passports. “When it comes to intellectual property, privacy, and so on, we need to make sure that those are dealt with either through encryption or through making data available at a later date. In each case, this will be done product by product and in full consultation,” said William Neale, adviser for circular economy at the European Commission’s environment department. Also adding: “[w]e’re talking about mostly existing data. We’re talking about a decentralised or distributed approach to the data. It does not have to move from where it’s created”.

Different industries will require tailored approaches to data storage and encryption to address security challenges. Data storage can either be centralised or decentralised; but given the significance of the data being shared, a centralised system with a private party in control of data storage and integrity could be a less secure scalable solution for digital product passport infrastructure. In some instances, a decentralised system provides the most effective means of data interoperability. 

Decentralisation also means the owner of the product is also the owner of the digital record, preventing reliance on a centralised system where data could be vulnerable to tampering. This approach complements the EU Data Strategy, which encourages the use of high-value, publicly accessible data to generate value for companies, governments, and consumers. Circularise’s product traceability system is customisable, enabling businesses to opt for a public, decentralised blockchain for enhanced transparency and security if needed.

Data encryption for DPPs: Protecting proprietary information

The concept of an open system sounds counterintuitive for protecting intellectual property, but this is where the topic of encryption comes in. Encryption can be done in various ways, e.g. using RSA (Rivest-Shamir-Adleman), end-to-end, or with zero-knowledge proofs. 

While RSA encryption is sufficient for most internet-based operations, and end-to-end encryption works well for messaging, neither fully addresses situations where data, especially proprietary information, must remain private. In cases where companies need to substantiate green claims without sharing sensitive details – even in encrypted form – these traditional encryption methods fall short of the transparency needed.

Here is where zero-knowledge proofs can provide a more flexible means of achieving this data transfer, allowing companies to provide proof of compliance without revealing sensitive product data. This method enables them to substantiate claims, such as material composition or operational processes without openly sharing the underlying data, thus balancing transparency with data protection. Circularise’s patented Smart Questioning solution allows our clients to selectively share information insight across a supply chain, without storing data or risking data security. 

Digital product passport growth opportunities

Implementing digital product passport systems and the required data management process could be a time-consuming and costly exercise that can hamper a business. Yet, DPPs offer the opportunity to explore new ways to differentiate themselves and grow. The challenge will be reaching the scale required to unlock the potential held within digital product passports in a way that is inclusive for all businesses and avoids excessive regulatory burdens that might stifle progress. 

Here’s how you can get the most out of a digital product passport system:

Gain a competitive edge

New product offerings with robust sustainability assurances backed by data from digital product passports can give supply chain actors a competitive market advantage. Products can then be marketed with trustworthy and quantifiable sustainability claims. This traceability data will allow more value to be created across supply chain tiers, driving a network-wide shift towards sustainability. As with batteries, some products will need to provide product lifetime data, this will also invite innovation and competition on product durability and longevity.

Introduce circular business models

This new digital connection throughout the supply chain can also be leveraged to strengthen relationships with downstream customers. A digital product passport opens up opportunities for circular business models centred on retained product ownership — models that were previously less feasible due to fragmented relationships across the value chain, particularly from the end customer through to end-of-life. By designing waste out of these systems, businesses can unlock new revenue streams and recapture value currently lost in end-of-life materials and waste. As business models become more circular, material sourcing options can be diversified, strengthening supply chain security.

Contact us to discuss generating value from circular business models.

Become a sustainability leader

When end-of-life processing options are integrated with a product, simpler material reuse cases will be encouraged. These tighter loops will offer simple and cost-effective solutions to sustainability challenges, avoiding and reducing the accumulation of valuable materials in the environment. Going through the process of digital product passport implementation will also enable manufacturers to gain a clearer view of their material flows and process efficiencies, paving the way for impactful improvements.

Use legislation compliance to your advantage

By pursuing early compliance and adopting voluntary certifications, companies can capture a larger market share. As traceability becomes a basic requirement for material procurement, developing robust product traceability and supply chain impact-tracking methods will position businesses as leaders.

Conclusion

Digital product passports will contain the information associated with products to effectively track and manage sustainability across their entire lifecycle. As you may expect, this means they will vary greatly depending on the product. While the implementation of DPPs started with batteries as the test case, these requirements will extend to a broader range of products as more legislations around product traceability and supply chain reporting come into play. 

The technology already exists to implement an effective digital product passport, but businesses will remain sceptical until feasibility has been demonstrated at scale. The investment required for DPP implementation, such as data infrastructure, compliance, supply chain integration, and cybersecurity, is necessary for creating flexible and scalable systems that will ultimately enable businesses to reduce future costs.

In the short term, DPPs offer companies the means to make credible sustainability claims and move towards circular-oriented innovation strategies, creating new value and capturing a greater market share. In the long term, this will favourably position them as sustainability leaders, aligning them with emerging regulations and market demands while contributing to a more circular economy.